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A missing element in the top down stock selection approach used by the UD Flyer Fund is the relative valuation of industry groups i.e. those groupings of firms below the sector level. In this study I analyze the relationship between returns to S&P industry groups and five different measures of relative valuation: (1) Price to Earnings (2) Price to Earnings (Forward) (3) Price to Book (4) Price to Cash Flow and (5) Price to Sales. Using a small but stratified sample of 18 industry groups (8 of 10 S&P sectors are represented), I regress returns on each of the relative valuation measures for two time periods: (1) 9-30-11 through 9-30-12 and (2) 12-31-11 through 9-30-12. I use R square, the B coefficients and their T statistics to measure the relationship between returns and the relative valuation measures.